# NIAGARA MOHAWK POWER CORP — Notice of Amendment

**Citation:** CPF 42025041NOA  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2025-08-29

CLOSED notice of amendment citing 193.2509(b)(3).

## Document text

Notice of Amendment involving NIAGARA MOHAWK POWER CORP. PHMSA's enforcement data identifies the cited regulation as 193.2509(b)(3). The case was opened on 2025-08-29 and is reported as closed as of 2025-11-25. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

42025041NOA_Closure Letter 11252025_(24-308458).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025041NOA/42025041NOA_Closure%20Letter%2011252025_(24-308458).pdf

42025041NOA_Closure Letter 11252025_(24-308458)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025041NOA/42025041NOA_Closure%20Letter%2011252025_(24-308458)_text.pdf

42025041NOA_Notice of Amendment_08292025_(24-308458).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025041NOA/42025041NOA_Notice%20of%20Amendment_08292025_(24-308458).pdf

42025041NOA_Notice of Amendment_08292025_(24-308458)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025041NOA/42025041NOA_Notice%20of%20Amendment_08292025_(24-308458)_text.pdf

42025041NOA_Operator Response to Notice_09262025_(24-308458).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025041NOA/42025041NOA_Operator%20Response%20to%20Notice_09262025_(24-308458).pdf

42025041NOA_Closure Letter 11252025_(24-308458)_text.pdf

U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration 8701 S. Gessner, Suite 630
Houston TX 77074
VIA ELECTRONIC MAIL TO: ross.turrini@nationalgrid.com
November 25, 2025
Ross Turrini
Chief Operating Officer, NY Gas Business
National Grid USA
25 Hub Drive
Melville, NY 11747
RE: CPF 4-2025-041-NOA
Dear Mr. Turrini:
From August 13 to 15, 2024 of the on-site inspection, a representative of the Pipeline and
Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United
States Code (U.S.C.), inspected Niagara Mohawk Power Corporation’sa (Niagara) procedures for
operations and maintenance of its liquefied natural gas (LNG) facility in Providence, Rhode Island.
As a result of the inspection, Niagar was issued a Notice of Amendement on August 29, 2025,
which proposed amendement of your procedures. Niagara submitted its amended procedures on
September 29, 2025. My staff has reviewed the amended procedures, and it appears that the
inadequacies outlined in this Notice of Amendment have been corrected.
This letter is to inform you no further action is necessary and this case is now closed. Thank you
for your cooperation.
Sincerely,
Bryan Lethcoe
Director, Southwest Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
cc: Keith Costa, LNG Compliance & Training Engineer, National Grid USA
keith.costa@nationalgrid.com
Andrew Kohout, Director, Division of LNG Facility Reviews and Inspections , Office of
Energy Projects, Federal Energy Regulatory Commission, andrew.Kohout@ferc.gov
aNiagara Mohawk Power Corporation is a subsidiary of National Grid USA.

42025041NOA_Notice of Amendment_08292025_(24-308458)_text.pdf

NOTICE OF AMENDMENT
VIA ELECTRONIC MAIL TO: ross.turrini@nationalgrid.com
August 29, 2025
Ross Turrini
Chief Operating Officer, NY Gas Business
National Grid USA
25 Hub Drive
Melville, NY 11747
CPF 4-2025-041-NOA
Dear Mr. Turrini,
From August 13 through 15, 2024 of the on-site inspection, a representative of the Pipeline and
Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United
States Code (U.S.C.) inspected Niagara Mohawk Power Corporation’s1 (Niagara) procedures for
operations and maintenance for its liquefied natural gas (LNG) facility in Providence, Rhode
Island.
As a result of the inspection, PHMSA has identified an apparent inadequacy found within
Niagara’s plans or procedures. The item inspected and the inadequacy is described below:
1. §193.2509 Emergency procedures.
(a) . . . .
(b) To adequately handle each type of emergency identified under
paragraph (a) of this section and each fire emergency, each operator
must follow one or more manuals of written procedures. The
procedures must provide for the following:
(1) . . . .
(3) Coordinating with appropriate local officials in preparation of
an emergency evacuation plan, which sets forth the steps required to
protect the public in the event of an emergency, including
catastrophic failure of an LNG storage tank.
1 Niagara Mohawk Power Corporation is a subsidiary of National Grid USA.



Niagara’s manual of written emergency procedures for its Providence, Rhode Island, LNG facility
was inadequate to handle each type of emergency identified under paragraph (a) of § 193.2509
and each fire emergency in accordance with §193.2509(b)(3). Specifically, Niagara's Facility
Response Plan, FRP-4 SP 7.0 failed to contain instructions on coordinating with the appropriate
local officials to prepare its emergency evacuation plan.
Niagara’s response plan did not include information or steps required to protect the public, such
as: which local authorities to contact in the event of an incident; requirements to host or participate
in emergency drills designed to prepare Niagara's personnel and local authorities to respond to
facility emergencies and foster cooperative relationships; guidance on how to coordinate with local
authorities during emergencies that require evacuation of the facility and community; or
requirements for records of drills or discussions with local authorities to be retained.
Therefore, PHMSA proposes that Niagara must update its manual of written emergency
procedures to include requirements to coordinate with local officials in preparation of an
emergency evaluation plan, which sets forth the steps required to protect the public in the event of
an emergency, including catastrophic failure of an LNG tank, in accordance with §193.2509(b)(3).
Response to this Notice
This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 CFR § 190.206. Enclosed as part
of this Notice is a document entitled Response Options for Pipeline Operators in Enforcement
Proceedings.
Please refer to this document and note the response options. Be advised that all material you
submit in response to this enforcement action is subject to being made publicly available. If you
believe that any portion of your responsive material qualifies for confidential treatment under 5
U.S.C. § 552(b), along with the complete original document you must provide a second copy of
the document with the portions you believe qualify for confidential treatment redacted and an
explanation of why you believe the redacted information qualifies for confidential treatment under
5 U.S.C. § 552(b).
Following the receipt of this Notice, you have 30 days to submit written comments, revised
procedures, or a request for a hearing under § 190.211. If you do not respond within 30 days of
receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice
and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice
without further notice to you and to issue an Order Directing Amendment. If your plans or
procedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans
or procedures to correct the inadequacies (49 CFR § 190.206). If you are not contesting this
Notice, we propose that you submit your amended procedures to my office within 30 days of
receipt of this Notice. This period may be extended by written request for good cause. Once the
inadequacies identified herein have been addressed in your amended procedures, this enforcement
action will be closed.



It is requested (not mandated) that Niagara maintain documentation of the safety improvement
costs associated with fulfilling this Notice of Amendment (preparation/revision of plans,
procedures) and submit the total to Bryan Lethcoe, Director, Southwest Region, Office of Pipeline
Safety, Pipeline and Hazardous Materials Safety Administration. In correspondence concerning
this matter, please refer to CPF 4-2025-041-NOA and, for each document you submit, please
provide a copy in electronic format whenever possible.
Sincerely,
Bryan Lethcoe
Director, Southwest Region, Office Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
Enclosure: Response Options for Pipeline Operators in Enforcement Proceedings
cc: Corinne Byrnes, Principal Program Manager – Federal Programs,
corinne.byrnes@nationalgrid.com

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/42025041NOA>
- Source ID: `phmsa-enforcement`
- SHA-256: `18bd698d1918e13110d1400d1e54653517da0d3bf828f41a34d20091b5d28076`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-23T13:14:35.392Z
- Document slug: `phmsa-enforcement-42025041noa`

### Source metadata

```json
{
  "cpf": "42025041NOA",
  "operator": "NIAGARA MOHAWK POWER CORP",
  "region": "Southwest",
  "pipelineType": "INTERSTATE LNG",
  "caseStatus": "CLOSED",
  "citedSections": [
    "193.2509(b)(3)"
  ],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
  "attachmentCount": 5,
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  "extractedAgencyDocumentCount": 2,
  "attachmentPolicy": "Official attachment links are retained. Agency-issued documents may also include a verified local PDF and page-level text representation.",
  "jurisdiction": "US",
  "operatorName": "NIAGARA MOHAWK POWER CORP"
}
```
